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Reporting Requirements for ARRA

Letter Head: Tom Torlakson, State Superintendent of Public Instruction, California Department of Education

August 28, 2009

Dear American Recovery and Reinvestment Act Subrecipients:


This letter is to provide information on and recommend next steps to meet the reporting requirements imposed as a condition of receiving American Recovery and Reinvestment Act (ARRA) of 2009 funds. Although a number of questions still remain related to the reporting requirements, I think it is imperative to share the information we have, so you may begin preparations to submit the required data. This letter focuses specifically on quarterly reports required by ARRA Section 1512.

ARRA subrecipients include school districts, county offices if education, charter schools, school food authorities, child development administrators, and Special Education Local Plan Areas.


On February 17, 2009, President Barack Obama signed the ARRA of 2009 into law. On a national level, $100 billion over a twoyear period is available for education reform. We estimate that California will receive nearly $8 billion in ARRA funds for prekindergarten to grade twelve education.

To date, the California Department of Education (CDE) has released $3.2 billion, including State Fiscal Stabilization Funds (SFSF) ($2.5 billion), Title I, Part A ($450 million), Individuals with Disabilities Education Act (IDEA) ($269 million), McKinney- Vento Homeless Assistance funds ($13.8 million), and Nutrition Equipment Grants ($12.8 million) to California’s public education system under the ARRA. The CDE expects to release Enhancing Education Through Technology (EETT) and Child Care and Development Fund (CCDF) grants in the near future.

The ARRA is clear that every dollar spent must be subject to unprecedented levels of transparency and accountability. To achieve this goal, the ARRA requires extensive reporting by entities receiving ARRA funding. Some reporting requirements apply to all ARRA funds, and some reporting requirements apply to specific programs. This letter addresses quarterly reporting under ARRA Section 1512, which applies to all entities receiving ARRA funds. Required reporting includes such matters as the number of jobs created and retained and the status of the project funded.

Quarterly Reporting

In accordance with the guidance on ARRA Section 1512 issued by the federal Office of Management and Budget (OMB), data on the use of ARRA funds by recipients (i.e., the state) and subrecipients (i.e., local educational agencies [LEAs] and other entities receiving funds through the state) are due to the federal government no later than the 10th day after the end of each calendar quarter. The first reports will be due to the federal government on October 10, 2009, and will cover the period from the grant award date through September 30, 2009. For the CDE to meet the federal reporting deadline, subrecipients will have to submit their data to the CDE in late September. We will confirm the exact due date soon.

Data Collection System

The CDE is constructing a Web-based data reporting system to collect information for each grant from subrecipients to comply with ARRA Section 1512 reporting requirements. We anticipate that the data system will be available for limited testing in early September and open to subrecipients later in September so subrecipients may input data in time to accommodate CDE review before the federal reporting deadline.

At this time, the CDE intends to follow the same procedures for password distribution to subrecipients that we used for LEAs in the SFSF application process. Passwords will be sent to each subrecipient by e-mail. Child development agencies will use their Contract and Tracking System (CATS) user ID and password to obtain access to the data reporting system.

Data Elements

Data elements to be collected from each subrecipient, for each grant, include (1) data that must be reported to the federal government at the subrecipient level (for example, the name of the subrecipient and the amount of each subaward) and (2) data that the CDE needs to collect from subrecipients to properly report at the recipient (state) level (for example, the number of jobs retained or created).

Some of the data elements that subrecipients are required to submit may be more challenging and therefore may require some additional preparation or forethought on the part of the subrecipient. The more challenging data elements include:

Data elements required for subrecipient-level reporting:

  • D-U-N-S Numbers. Subrecipients will be required to provide a Dun & Bradstreetissued D-U-N-S Number. Subrecipients that receive funding directly from the federal government should already have a D-U-N-S Number. Any entity that does not have a D-U-N-S Number is encouraged to apply for one immediately. (Please see the attachment for instructions on how to apply for a D-U-N-S Number) Although the federal Web site states that D-U-N-S Numbers can be obtained in one day, I encourage entities needing D-U-N-S Numbers to apply immediately as the number of requests may overwhelm the federal system and lead to lengthy delays.
  • Vendor data. Subrecipients will be required to provide information related to any vendors that the subrecipient paid or was invoiced for more than $25,000 in ARRA funds. The required information includes the name and zip code of the vendor or the vendor’s D-U-N-S Number.
  • Names and compensation of the five most highly compensated individuals. The data requirement applies only to subrecipients that in previous fiscal years received 80 percent or more of their revenues from federal funds, that have annual federal revenue exceeding $25 million, and that are not required to make compensation information available to the public. Thus the requirement applies to very few, if any, subrecipients for the ARRA grants that CDE manages.

Data elements required from subrecipients to be aggregated for recipient-level reporting:

  • Project status. Subrecipients will be required to report on the completion status of each subaward by providing the amount of grant dollars that have been expended to date. This data is required to enable the state to calculate the percentage of the work that has been completed.
  • Number and type of jobs retained or created. We expect more guidance on this data element from the U.S. Department of Education (ED). Subrecipients will be required to estimate the number of jobs that have been retained or created that can be attributed to the ARRA grant, and provide information on the types of jobs retained or created. The estimate of the number of jobs should be expressed in “full-time equivalents” (FTEs). To convert hours worked to number of FTEs, subrecipients will need to aggregate all hours worked and divide by the number of hours in a full-time schedule for the time period of the report. This data will be used to calculate the total number of jobs that were retained or created statewide that are directly related to the ARRA grant.
  • Infrastructure spending, purpose and rationale. The OMB has not yet defined “infrastructure” and we expect more guidance on this issue from the ED. Subrecipients will be required to provide the amount spent for infrastructure and to explain the purpose and rationale for funding infrastructure with ARRA funds. The explanation will need to include how the infrastructure investment will preserve and create jobs and promote economic recovery; assist those most impacted by the recession; spur technological advances; provide long-term economic benefits; and stabilize state and local governments. Because few ARRA grants allow the funds to be used for infrastructure, and because of the other demands on ARRA funds, this data element will not likely apply to many subrecipients. This data is required so that the state may report how the infrastructure investment will contribute to one or more purposes of the ARRA.

For ease of reporting, the CDE will preload as much data as possible, including the subrecipient’s name, location and contact, and grant award amounts. We also intend to provide drop-down or check boxes, to the extent possible, to simplify data entry.

We note that the OMB requirements may change in future reporting periods and we may change our data reporting system to accommodate those changes.

Preparatory Actions

In anticipation of the upcoming reporting period, we recommend that all LEAs and other subrecipients receiving ARRA funding through the CDE immediately do the following:

  • Determine whether you have a D-U-N-S Number and apply for one if necessary.
  • Identify and correct any outstanding issues that arose from the SFSF password distribution process. If necessary to contact the CDE, please send an e-mail to
  • Sign up for the CDE ARRA listserv by sending a blank e-mail to

As I previously mentioned, many questions still remain about the reporting requirements. The ED plans to release additional guidance and tip sheets to assist ARRA grant recipients and subrecipients in complying with ARRA Section 1512 data reporting requirements. As we receive additional information from the federal government about ARRA Section 1512 requirements—and about program specific reporting—we will share it with you. We will continue to keep you apprised of developments concerning ARRA implementation through the listserv and on the CDE ARRA Web page at I will also issue a followup communication with more detailed information on the data reporting elements prior to the time that subrecipients must submit their data.

If you have any questions regarding ARRA reporting, please contact the Fiscal Policy Division by phone at 916-319-0658 or by e-mail at You may also contact Linda Hakala, Education Fiscal Services Consultant, Fiscal Policy Division, at 916-319-0658.